IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ADAM STRATTON,
Petitioner,
v.
LargeTitanic2, in his official capacity as
President of the Senate of the State of
Ridgeway,
Respondent.
Case No. ____________________
EMERGENCY PETITION AND
MOTION FOR STAY OF
CONTEMPT ORDER
Immediate relief requested
Adam Stratton petitions the Court for relief from an order holding him in contempt of the
Senate, and moves for an emergency stay of that order until the petition is decided. On September
16, 2026, the Respondent, presiding over the Senate, declared the Petitioner in contempt on the
ground that he had disrupted the proceedings by making “outlandish statements.” The Senate did
not vote. The Petitioner was given no notice of a charge and no chance to answer one. The order
exposes him to arrest, to imprisonment for up to twenty minutes, and to a misdemeanor record
under R.C.C. § 1.06. A sentence that short will be served before any ordinary motion can be heard,
and no later ruling can give the time back. The Petitioner asks the Court to stay the order now and to
decide its legality afterward.
PARTIES AND JURISDICTION
1. The Petitioner, Adam Stratton, is a resident of the State of Ridgeway and holds the office of
Attorney General. He brings this petition in his personal capacity. The contempt order runs
against him personally, and the liberty at stake is his own. He does not appear for the State
or for the Department of Justice.
2. The Respondent, LargeTitanic2, is the President of the Senate, an office the Constitution
assigns to the Lieutenant-Governor. Const. art. III, § VI. He is named in his official
capacity. A proceeding against an officer in his official capacity is construed as a case
against the government. 7 R. Stat. § 122.004.
3. The Superior Court is “a court of law and equity,” 3 R. Stat. § 131.001, with original
jurisdiction over all civil and criminal cases or controversies. Const. art. V, § IV. That
jurisdiction covers “[a]ll felony and misdemeanor crimes under the Ridgeway Criminal
Code,” “[a]ll civil claims,” and “[a]ny controversy not otherwise falling within the
jurisdiction” of another court. 3 R. Stat. § 131.004(a), (c), (e). Contempt of Senate is a
misdemeanor under the Ridgeway Criminal Code. R.C.C. § 1.06.
4. The petition rests on three sources of relief. First, any government “order” that “impedes on
an individual’s rights, immunities, or privileges secured by state statute or the constitution”
is subject to injunctive relief “against the government,” including relief “reversing any
harm done.” 7 R. Stat. § 122.101. Because that section expressly creates liability against
the government, sovereign immunity does not apply. 7 R. Stat. § 122.002. Second, every
person who, under color of law, deprives another of rights secured by the Constitution and
laws is liable “in an action at law, suit in equity, or other proper proceeding for redress.”
7 R. Stat. § 121.403. Third, to the extent the Petitioner has been or is taken into custody
under the order, he seeks the writ of habeas corpus, which this Court is empowered to
provide, which may be sought “at any time,” and which is not mooted by release. Const.
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art. V, § IV; 7 R. Stat. §§ 133.001, 133.004. If another officer makes the arrest, the
Petitioner will add that officer as a respondent. 7 R. Stat. § 133.002.
5. The defense of this proceeding belongs to the Solicitor General. 7 R. Stat. § 122.005.
Because the Solicitor General serves at the pleasure of the Attorney General, 2 R. Stat.
§ 122.002, the Petitioner states for the record that he has withdrawn from any official role in
this matter, that he will give the Solicitor General no direction concerning it, and that he
will take no action against any officer of the Department of Justice on account of the
defense of it.
6. For the same reason, the mediation step in 2 R. Stat. § 123.001 cannot be performed here.
That section makes the Attorney General the initial arbitrator of civil claims against agents
of the State. The Petitioner cannot arbitrate his own claim and will not purport to. Were the
duty to pass to the Deputy Attorney General under 2 R. Stat. § 121.107, the arbitrator
would be the Petitioner’s own subordinate, which cures nothing. A step that cannot
lawfully be taken does not close the courthouse to a person facing imprisonment, who is
entitled to justice “promptly and without delay.” Const. art. I, § I. The habeas ground is in
any case outside § 123.001, because the writ may be sought “at any time.” 7 R. Stat.
§ 133.001.
FACTS
7. On September 16, 2026, the Senate was in session with the Respondent presiding. The
Petitioner was present and spoke.
8. The Respondent declared the Petitioner in contempt of the Senate. The ground he gave was
that the Petitioner had disrupted the proceedings of the Senate by making “outlandish
statements.”
9. The Respondent made that declaration alone, from the chair. No Senator moved that the
Petitioner be held in contempt, no question was put to the body, and no vote was taken.
10. The Petitioner was given no statement of any charge before the declaration was made, no
opportunity to answer it, and no opportunity to be heard by counsel. The Respondent made
no finding that the Petitioner had obstructed the session, as distinct from saying things the
Respondent found objectionable.
11. The order has not been withdrawn. It exposes the Petitioner to arrest, to imprisonment for
up to twenty minutes, and to a misdemeanor record. R.C.C. § 1.06.
GROUNDS FOR A STAY
The Code sets no separate standard for interim relief, so the Petitioner applies the settled
test for a stay: whether the movant is likely to succeed, whether he will be irreparably harmed
without a stay, whether a stay will injure the other side, and where the public interest lies. Nken v.
Holder, 556 U.S. 418, 434 (2009). Decisions of the Supreme Court of the United States are cited in
this petition as persuasive authority and, on the First and Fourteenth Amendments, as controlling.
Every factor favors a stay.
A. The Petitioner is likely to succeed.
1. Only the Senate can order a charge of contempt of the Senate, and the Respondent is
not the Senate.
The Legislature did not leave the contempt power at large. Under the Contempt of Senate
subsection of the Crime and Criminal Procedure Act, no charge “shall be held against a person,
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except upon order of the Senate.” Crime and Criminal Procedure Act of 2026, S.B. 002, § 403(a)
(i); see R.C.C. § 1.06 (offense “punishable by order”). The subsection’s text says “contempt of
court,” a drafting slip carried over from the parallel provision at § 404(a)(i); it sits under the
Contempt of Senate offense and names the Senate as the ordering body. If the slip were instead read
literally, § 403(a) would give no authority to charge contempt of the Senate by order at all, and the
offense could be charged only as other misdemeanors are. The Respondent’s declaration fails on
either reading.
The Senate is a body of nine Senators, and it acts through a quorum of them. Const. art. III,
§§ V, VI. The President of the Senate is not one of them. He is the Lieutenant-Governor, he
presides, and he “shall have no Vote, unless the Senate be equally divided.” Id. § VI. An order of
the Senate is something the Senators make, by a question put and carried. A declaration from the
chair is not one. The Respondent did by himself what the statute allows only the body to do.
The defect is more than a formality. The Lieutenant-Governor is an officer of the executive
department. Const. art. II, §§ I, III. The Constitution keeps the three departments “separate and
distinct, so that neither exercise the powers properly belonging to the others.” Id. § V. When an
executive officer, acting alone, adjudges a person guilty of a misdemeanor and commits him to
imprisonment, he exercises a power that belongs to the Senate by statute or to the courts by the
Constitution. In neither case does it belong to him.
2. Making statements is not obstructing a session.
R.C.C. § 1.06 reaches two things: failing to appear on a lawful subpoena or writ of
command, and “obstruct[ing] any session of the whole or partial Senate,” in either case “without
lawful justification.” The Respondent did not find that the Petitioner blocked, halted, or prevented
the Senate from proceeding. He found that the Petitioner made statements and that the statements
were outlandish. That is a judgment about what was said. It is not a finding of obstruction.
The neighboring section shows that the difference was deliberate. For contempt of court,
the Legislature wrote a broad offense covering “disorderly, contemptuous, or insolent behavior”
and any “noise, or other disturbance directly tending to interrupt the proceedings of the court.”
R.C.C. § 1.08. For contempt of the Senate it wrote none of that. It chose one word, “obstructs.” The
language the Legislature left out of § 1.06 cannot be borrowed from § 1.08. Nor did the Respondent
find the culpability the law requires. A person is not guilty of an offense unless he acted with the
required culpability “with respect to each material element,” and where the offense names none,
the element is established only by purpose, knowledge, or recklessness. 6 R. Stat. §§ 121.002,
121.003.
The Supreme Court of the United States drew the same line in a case much like this one. In
Marshall v. Gordon, 243 U.S. 521 (1917), a United States Attorney who was the subject of an
impeachment inquiry sent the chairman of the investigating House subcommittee a letter the House
found defamatory and insulting. The House held him in contempt and ordered his arrest. The Court
ordered him discharged on habeas corpus. A legislature’s contempt power exists to remove
obstructions to its work, and it does not reach a statement merely because the body is affronted by
it. See also Anderson v. Dunn, 19 U.S. (6 Wheat.) 204, 231 (1821) (legislative contempt is confined
to “the least possible power adequate to the end proposed”).
If § 1.06 could be stretched to cover statements, it would collide with the Constitution. The
people have a right to freedom of speech “concerning the transactions of government.” Const.
art. I, § IX; U.S. Const. amend. I. Speech addressed to the Legislature is at the center of that right.
See Bond v. Floyd, 385 U.S. 116 (1966) (state legislature violated the First Amendment by
excluding a member-elect because of his statements on public questions). A penal statute is read to
avoid that collision.
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The Petitioner does not dispute that the Senate may keep order. The Constitution says how:
the doors of the Senate are open to “all persons who behave decently,” Const. art. II, § VI, and a
person who does not may be shown out. Removal protects the proceedings completely.
Imprisonment adds only punishment.
3. The Petitioner received no notice and no hearing.
Contempt of Senate is a criminal offense, a misdemeanor punished by imprisonment in a
state penitentiary. S.B. 002, § 403(a). The Constitution provides that “in all prosecutions for
criminal offenses, a person hath a right to be heard by oneself and by counsel” and “to demand the
cause and nature of the accusation,” and that no person can “be justly deprived of liberty, except by
the laws of the land, or the judgment of the person’s peers.” Const. art. I, § VI. The Petitioner
received none of it. He was accused, judged, and sentenced at once, by the officer who took
offense.
The Fourteenth Amendment forbids the same thing. Groppi v. Leslie, 404 U.S. 496 (1972)
(state legislature denied due process by punishing a non-member for contempt without notice or an
opportunity to be heard). Groppi involved punishment imposed two days after the event, and the
Court did not decide whether a legislature may act summarily, in the moment, to stop a disturbance.
But stopping a disturbance requires only removal. Nothing about the moment required a criminal
judgment and a jail term without a word from the accused.
4. Article I, Section X does not bar review.
The Respondent may invoke Article I, Section X, which protects “[t]he freedom of
deliberation, speech, and debate, in the Legislature” from being made the foundation of an “action
or complaint, in any other court or place whatsoever.” The clause does not reach this case. An order
adjudging a person guilty of a crime and committing him to prison is not deliberation, speech, or
debate. It is the application of a penal statute to a person outside the body. Courts have reviewed
legislative contempt orders on that footing since Kilbourn v. Thompson, 103 U.S. 168 (1881)
(holding a contempt order of the House of Representatives void and permitting an action for false
imprisonment against the officer who executed it). See also Powell v. McCormack, 395 U.S. 486
(1969) (Speech or Debate Clause did not bar review of the legality of legislative action in a suit
against the officers who carried it out). The Legislature has said the same. It placed all
misdemeanors under the Criminal Code, contempt of the Senate among them, within this Court’s
original jurisdiction, 3 R. Stat. § 131.004(a), and the Constitution gives this Court the writ of
habeas corpus with no exception for prisoners of the Senate. Const. art. V, § IV.
B. The harm cannot be undone.
A twenty-minute sentence is over before any ordinary motion can be heard. Time in
custody cannot be returned, and an unlawful jail term is not made lawful by being short. The order
also punishes speech, and “[t]he loss of First Amendment freedoms, for even minimal periods of
time, unquestionably constitutes irreparable injury.” Elrod v. Burns, 427 U.S. 347, 373 (1976)
(plurality opinion). The Legislature saw the problem when it provided that habeas corpus is not
mooted by release. 7 R. Stat. § 133.001. A ruling after the fact is still a poor substitute for never
having been jailed.
C. A stay injures no one and serves the public interest.
A stay costs the Respondent and the Senate nothing. The Senate remains free to conduct its
business, to keep order in its chamber, and, if it chooses, to take up a contempt charge by vote of its
members after notice and a hearing. With a stay, the question is decided by a court. Without one, it
is decided by the running of a jail timer. The public interest lies in having the limits of the contempt
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power settled before a person is imprisoned under it. That interest does not depend on who the
Petitioner is, and it would be the same for any resident of the State.
RELIEF REQUESTED
The Petitioner respectfully requests that the Court:
(a) immediately, and without awaiting a response, stay the contempt order of September 16,
2026, and all enforcement of it, including any arrest, booking, imprisonment, or entry of an
offense record against the Petitioner, until this petition is finally decided;
(b) if the Petitioner is in custody under the order when this motion is reached, order his
immediate release;
(c) direct the Respondent and the Solicitor General to respond within a time the Court sets, and
set the petition for hearing;
(d) on final decision, declare the contempt order void, permanently restrain its enforcement,
and order any offense record arising from it expunged, 7 R. Stat. § 122.101; Const. art. V,
§ IV; and
(e) grant such further relief as the Court deems just and proper.
A proposed order is submitted with this petition.
Respectfully submitted this 16th day of September, 2026.
/s/ Adam Stratton
ADAM STRATTON
Petitioner, in his personal capacity
VERIFICATION
I, Adam Stratton, affirm under the pains and penalties of perjury that the facts stated in
paragraphs 1 through 11 of this petition are true.
/s/ Adam Stratton
ADAM STRATTON
Petitioner
CERTIFICATE OF SERVICE
I certify that on September 16, 2026, this petition and motion, together with the proposed
order, was filed with the Clerk of the Superior Court, and that a copy was served by electronic
means upon the Respondent, LargeTitanic2, and upon the Solicitor General. 7 R. Stat. §§ 131.103,
131.106, 133.003.
/s/ Adam Stratton
ADAM STRATTON
Petitioner
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IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ADAM STRATTON,
Petitioner,
v.
LargeTitanic2, in his official capacity as
President of the Senate of the State of
Ridgeway,
Respondent.
Case No. ____________________
[PROPOSED] EMERGENCY
ORDER STAYING
CONTEMPT ORDER
This matter is before the Court on the Petitioner’s Emergency Petition and Motion for Stay
of Contempt Order. Upon review of the verified petition, the Court finds that the Petitioner has
shown a likelihood of success on the merits, that he will suffer irreparable harm without immediate
relief, and that a stay will not injure the Respondent or the public interest. IT IS HEREBY
ORDERED:
1. The motion is GRANTED.
2. The order of September 16, 2026, holding the Petitioner, Adam Stratton, in contempt of the
Senate is STAYED until further order of this Court.
3. While this stay is in effect, the Respondent, and every person acting at his direction or under
the contempt order, shall not arrest, book, detain, or imprison the Petitioner, or enter any
offense record against him, under that order. If the Petitioner is in custody under that order,
he shall be released immediately.
4. The Respondent and the Solicitor General shall respond to the petition within
____________ of this Order. The petition is set for hearing on ____________________.
5. The Clerk of the Superior Court shall transmit a copy of this Order to the Respondent, the
Solicitor General, and the Sergeant-at-Arms of the State Senate.
SO ORDERED this ______ day of ____________________, 2026.
____________________________________
Judge, Superior Court of the State of Ridgeway
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